Last Updated: 2/10/2021
1. Information about us (data controller)
2. Data collection and use
We will collect certain data (which may be personal or anonymous) in order to provide the Filma App and services, process your payments, improve the Filma App and communicate with you where relevant. Some of the data we collect may be provided by you willingly, collected by us automatically (through cookies and third-party tools) or through your permission. Below are the categories of data collected and why:
The data you provide willingly
We collect the data you submit to us willingly. This data may be submitted by you under the below circumstances:
Personal data: Personal data is any data (or information) that can identify you. This may include your picture, email address, IP Address and name. Where we collect personal data in relation to the Filma App and services, we try as much as possible to keep you anonymous via various measures.
Contact data: If you contact us via our email address or the “contact us” form, we will retain the email address with which you reached out. This will enable us to reply to your questions, complaints or enquiries.
Registration and profile data: When you use the “Sign in with Apple” feature provided by Apple Inc. (“Apple”) to create an account on the Filma App, we will automatically collect the data you have with Apple, including your Apple ID and email address, to create an account for you. The data we will have access to when you use this feature includes your username and email address (if you share it). We will only collect this data to provide you with a Filma account to enable you to use certain features. Also, we will collect the data you submit when you fill the sections on your profile, including your profile image, bio and social media profile links (some of which are optional).
Payment method data: To process your payments for any in-app purchase, we will collect the payment method set up on Apple. We do not store any payment method data on our database. All payments are handled and processed by Apple as a third-party service provider.
Content data:If you submit content on the Filma App, including commenting on posts created by other users and sharing your license, the data contained in your submission will be collected and retained on the particular area of the Filma App. We will not reveal any personal data when you submit contents unless you willingly share such data.
The data we collect automatically
Usage data: When users download or access the Filma App by or through an Apple device, we may collect certain anonymous data, including, but not limited to, the number of users and downloads, the type of device used, the device unique ID, the IP address of the device and Operating System (OS), the type of mobile Internet browser, unique device identifiers and other diagnostic data. We also collect the details of crash reports. This data helps us to enforce our Terms of Service and comply with applicable laws.
Transaction data: If you purchase any premium features on the Filma App, we will automatically collect the details of that transaction, which may include the feature purchased, the amount paid, the date and time and the payment method used (with no personal data).
Face Tracking and Object tracking usage: When you make use of our Tracking features (Face Tracking or Object Tracking), we record the position of these features locally on the Filma App's database with no link at all to any identity. The only data gathered from the detection is the position or location of these objects in order to be able to link or perform video editing tasks such as overlays, effects or adjustments on the media that will use the position data to move along with the subject detected (face or object selected). This unlinked to identity and abstract data will always be located inside the Filma App and won't be shared with any other party.
Data from your permissions
To provide certain features of the Filma App (such as importing your pictures, videos, music and send you notifications), we may require access to certain features in your device, including camera, gallery and push notifications. We will only obtain access to these features strictly by your permission (when you allow it). And where you wish to revoke your permission, you may do so by using the “permission” settings on your Apple device.
3. Cookies and third-party service and tools
Examples of the cookies we use are:
Session Cookies. We use Session Cookies to operate our service. These types of cookies only last for a browsing session. They expire when you close your browser or Filma App.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes – to secure the Filma App and website.
Third-party service and tools
We may use third-party service providers to monitor and analyse the use of the Filma App and service. We use Firebase, a third-party tool provided by Google and Apple’s services to gather some of the data we gather automatically above.
4. Use of collected data
We use the data we collect above primarily to provide the Filma App and service. More detailed uses include:
To provide and maintain the Filma App and service;
To enable you import your content to the Filma App;
To process your payments for any in-app purchase;
To enable you share your content to your social media profiles, friends, family and other users;
To notify you about new features or changes to the Filma App and other administrative messages, and to provide customer care and support;
To allow you to participate in interactive features of the service when you choose to do so;
To provide analytics or valuable information that we can use to improve the Filma App and service;
To monitor your use of the Filma App and identify the parts that need improvements and upgrades;
To comply with applicable laws; and
To fulfil any other purposes disclosed at the time of collection.
5. Data sharing and disclosure
We do not share or disclose personal data about you to third parties for them to market to you. We will only disclose or share personal data about you unless as described below or as described to you at the time of disclosure.
- Disclosure to service providers: We may hire the services of third-party service providers to perform services such as payment processing, app hosting and distribution, database management and storage, fraud detection, analytics gathering and app maintenance. These service providers may have access to certain personal data about you (for example, we store your data using Google’s Firebase).
- Disclosure to other users: If you share certain content with other users of the Filma App, or you comment on another user’s content, such users will have access to any personal data attached to such content. Also, the data on your profile (including any profile image) may be accessed by any user who navigates to your profile area.
- Disclosure to users of other services: If you share content through the social media sharing features on the Filma App, any personal data attached to such content will be accessible to any user who accesses such content.
- Disclosure under the law: We may disclose personal data in the good faith belief that such disclosure is necessary to: (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) prevent or investigate possible wrongdoing in connection with the Filma App, (iv) protect the personal safety of users of the Filma App or the public, or (v) protect against legal liability.
- Disclosure under a business transfer: We may disclose personal data in the event of an acquisition, consolidation, sale of assets or merger between us and another company or entity.
6. Security of data
Also, we save and secure the collected data on Google’s secure cloud storage, Firebase. We do not have access to any payment method data you use for any payment made in relation to any in-app purchase. Such payments are handled by Apple securely.
However, due to the nature of the internet, we cannot guarantee that your personal data will always be private or that unauthorised parties will not access it. We use commercially reasonable measures to safeguard your privacy, but we cannot give a 100% guarantee.
7. Retention of data
Unless you request that we remove some data about you (as described under your rights below), we will retain your data with us for as long as you use the Filma App. However, when you request to delete certain data about you, we may be unable to delete specific data for business continuity purposes or in line with applicable legal requirements. IP Addresses collected will be retained in accordance with Google’s retention policy. Firebase logs and retains your IP address temporarily. To find out more about Firebase’s retention period, click here.
8. International transfer of data
Your data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction (for example, Apple may process your payments from the United States).
For transfers of data about users in the European Union (EU) and countries under the General Data Protection Regulation (GDPR), we rely on the European Commission’s approved data transfer mechanisms.
9. Do Not Track signals
Your browser may contain a Do Not Track (“DNT”) signal, which may be transmitted to websites and services you visit to stop tracking your navigations on such websites and services. Under California’s CalOPPA, we are required to tell you if we respond to DNT signals. At this time, we do not respond to DNT signals. You may find out more about DNT signals at www.allaboutdnt.com.
10. Your data rights and choices
- You may request access to and correct the data we hold about you at any time. You may access your profile area at any time and correct the data available therein, including your picture, bio, social media account, etc.
- You may remove the personal data and user account you have with us to the extent possible. You may sign off your account and delete it via the “remove account” button of your Filma profile section.
- You have a choice to not provide any data we require from you. However, where such data requested will help us to provide a service or function, please be aware that we may not be able to provide such function or service if you do not provide the data.
11. Additional disclosures for users in the EU
If you are using the Filma App and service from the European Union (“EU”) or any country under the General Data Protection Regulation (“GDPR”), this section applies to you.
We are required to process and transfer personal data about you in accordance with the GDPR. As described above, we are your data controller. We will only process your personal data under the following legal basis:
- Consent: We will collect some of the personal data above if you expressly consent to it (for example, where you sign up to use the Filma App and provide your data).
- Legal obligations: We will collect some data, such as transaction data, to comply with our legal obligations (for example, where we are required by applicable law to keep records).
- Legitimate interest: We will collect certain data automatically where such collection satisfies our legitimate interest (for example, where we gather usage data so as to identify how the Filma App is used and provide improvements).
- Contract performance: We will collect certain data in order to fulfil our obligations to you.
In addition to the rights and choices discussed in the section above, you have the following rights in relation to your data:
- The right to limit processing: It may sometimes be possible to restrict the processing of your data so that it can only be used for specific purposes (for example, for legal claims or to exercise legal rights). In such situations, we would not use or share your data in other ways while processing is restricted. You can ask us to restrict the use of your data if (i) it is inaccurate, (ii) it has been unlawfully used, but you do not want us to delete it; (iii) it is no more relevant, but you want us to keep it for use in legal claims, and (iv) you have already requested that we stopped using it, but you are waiting for us to tell you if we are allowed to keep using it.
- Right to object to profiling: The GDPR gives you the right to object to the processing of your data. This effectively allows you to ask us to stop processing your certain personal data (for example, where we use your email address to send you newsletters, you will have the right to opt out).
- Right to portability: The right to data portability permits you to collect and reuse your data for any purposes across different services. It allows you to move, copy or transfer your data easily from our service to another service in a safe and secure way, without affecting its usability.
- Right to reporting: You have the right to report us to any data authority in the location you are if you believe that we are unlawfully processing your data.
You may exercise the above rights by reaching out to us at email@example.com or using the profile area of your Filma account where possible.
12. Additional disclosure for users in California
If you are using the Filma App from the State of California, the United States, this section applies to you. Under the California Consumer Privacy Act (“CCPA”), you have the below additional rights in relation to your data:
- The rights to know about the data we collected or shared with third parties in the past 12 months calendar.
- The rights to request the deletion of personal data about you. However, be aware that this does not include (i) any data we are required by applicable law to retain (e.g., transaction data), (ii) any data that exists in copies shared with service providers, or (iii) any data you have previously shared with other users through the Filma App.
- The right to request that we remove your data from being sold or rented to third parties for them to market to you. Fortunately, we are not in the business of selling or renting out personal data to third parties for their business purposes.
- You have the right to exercise any of the above rights without us discriminating against you regardless of your race, colour, sexual orientation, religion, status or interest.
To exercise any of the above rights as a user from California, you may reach out to us via our email address at firstname.lastname@example.org. Please, be aware that we may attempt to verify your location.
13. Links to third-party services
14. Children's privacy
The Filma App does not address anyone under the age of 18 (“Child” or "Children"). We do not knowingly collect data from Children. If you are a parent or guardian and you are aware that your Child has provided us with personal data, please contact us email@example.com. If we become aware that we have collected personal data from a Child without verification of parental consent, we will take steps to remove that data from our servers.
16. Contact us